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Parker v. Allen

Citations: 565 F.3d 1258; 2009 U.S. App. LEXIS 8275; 2009 WL 1034804Docket: 05-16907

Court: Court of Appeals for the Eleventh Circuit; April 20, 2009; Federal Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

This case involves John Forrest Parker's appeal of the denial of his habeas corpus petition, which sought to overturn his 1988 capital murder conviction and death sentence. Parker was convicted for the murder of Dorlene Sennett, a crime committed for financial gain. His appeal raised issues under Batson v. Kentucky, alleging racial discrimination in jury selection, which was rejected by the court. Parker also contended that improper prosecutorial comments and vouching during closing arguments violated due process, but the court found no miscarriage of justice. Furthermore, Parker argued ineffective assistance of counsel and Brady violations for nondisclosure of a witness's criminal history, neither of which were upheld by the court. Parker's claims regarding the Fourth Amendment and probable cause for his arrest were also unsuccessful, as the court found the arrest justified based on corroborated informant information. Ultimately, the court affirmed the district court's denial of habeas relief, finding that Parker's claims did not demonstrate a violation of established law or unreasonable application of facts.

Legal Issues Addressed

Batson Claim and Jury Selection

Application: Parker's appeal included a Batson claim alleging racial discrimination in jury selection, but the trial court found no violation, and this was upheld upon review.

Reasoning: The trial judge concluded that the prosecution did not violate Batson by excluding eight black jurors and determined that the aggravating factor of pecuniary gain outweighed mitigating factors such as Parker's lack of prior criminal history and remorse.

Brady Violation

Application: Parker alleged a Brady violation due to nondisclosure of a witness's full criminal history, but the court found no suppression of material evidence.

Reasoning: The Alabama Court of Criminal Appeals found no evidence that the prosecution suppressed evidence, noting that Parker's claims were based solely on coincidental facts.

Fourth Amendment and Probable Cause

Application: Parker challenged the probable cause for his arrest, but the court found that corroborated information from an informant established a sufficient basis.

Reasoning: The court's findings indicate that the issues surrounding Parker's arrest and subsequent statements did not undermine the legality of the police's actions or the admissibility of his statements.

Habeas Corpus under 28 U.S.C. § 2254

Application: Parker sought to overturn his 1988 capital murder conviction and death sentence through a habeas corpus petition, which was ultimately denied by the district court and affirmed on appeal.

Reasoning: John Forrest Parker appeals the dismissal of his habeas corpus petition under 28 U.S.C. § 2254, which sought to overturn his 1988 capital murder conviction and death sentence.

Ineffective Assistance of Counsel

Application: Parker claimed ineffective assistance of counsel, but the court found his representation during trial and sentencing was not prejudicial to his defense.

Reasoning: The district court was correct in determining that state courts reasonably applied the Strickland standard when rejecting Parker's ineffective assistance of counsel claim.

Prosecutorial Misconduct in Closing Arguments

Application: Parker argued that improper closing arguments by the prosecutor, including vouching for witnesses, were unreasonable, but the court found no due process violation.

Reasoning: The Alabama Court of Criminal Appeals determined that the prosecutor's remarks were improper attempts to enhance witness credibility through vouching. Despite recognizing the comments as clearly erroneous, the court concluded that they did not compromise the trial's fundamental fairness or result in a miscarriage of justice.